The General Assembly may provide for the ad valorem taxation
by the State or any of its subdivisions of all real and personal property.
The assessment of all property shall be equal and uniform in the following
classifications:

. . .

(5) All other real property not herein provided for shall
be taxed on an assessment equal to six percent of the fair market value of such
property.

S.C. Const. art. X, § 1 (emphasis added).

It further provides:

The General Assembly may define
the classes of property and values for property tax purposes of the classes
of property set forth in Section 1 of this article and establish administrative
procedures for property owners to qualify for a particular classification.

S.C. Const. art. X, § 2 (a).

The statute at issue states:

For purposes of property taxation,
each time share unit, operating under a “vacation time sharing ownership plan”
as defined in item (8) of § 27-32-10, must be valued in the same manner as
if the unit were owned by a single owner. The total cumulative purchase price
paid by the time-share owners for a unit may not be utilized by the tax assessor’s
offices as a factor in determining the assessed value of the unit. A unit operating
under a “vacation time sharing lease plan” as defined in item (9) of § 27-32-10,
may, however, be assessed the same as other income producing and investment
property.

S.C. Code Ann. § 27-32-240 (1).

Beaufort County construes the sentence “[t]he assessment
of all property shall be equal and uniform in the following classifications”
in § 1 as mandating the Legislature value property in each subset of the section
uniformly. Beaufort County relies upon this Court’s previous decisions which
provide: “The word ‘assessment’ used in the Constitution and the statutes means
‘the value placed upon property for the purposes of taxation by officials appointed
for that purpose.’” Meredith v. Elliot, 247 S.C. 335, 342, 147 S.E.2d
244, 247 (1966) (citingOwings Mills, Inc. v. Brady, 246 S.C.
361, 143 S.E.2d 717 (1965)); seealsoSimkins v. City of Spartanburg,
269 S.C. 243, 237 S.E.2d 69 (1977).

Beaufort County avers this definition clarifies
the Constitution as requiring “[t]he [value placed upon property for the purposes
of taxation] shall be equal and uniform in the following classifications. .
.” As such Beaufort County believes the Legislature cannot require a local
assessor to value similar property differently as is mandated by § 27-32-240.

The ad valorem tax is a product
of three separate sets of numbers: the assessment ratio, the millage rate, and
the fair market value of the property. Ad valorem taxes are calculated
by multiplying the fair market value of a property by its assessment ratio to
obtain the assessed value. The assessed value is then multiplied by the millage
rate to determine the property tax owed. Homeowner’s Guide to Property Taxes
in South Carolina, South Carolina Dep’t of Revenue 3; seealsoNewberry Mills Inc. v. Dawkins, 259 S.C. 7, 190 S.E.2d 503 (1972) (discussing
assessment ratio, millage rate, values and calculation of property tax).

Section 2 of Article X further confers
upon the Legislature the power to “define the classes of property and values
for property tax purposes of the classes of property set forth in Section 1.”
The section is logical only if read to allow the Legislature to define sub-classes
of property for those classes enumerated in § 1 and to determine how each sub-class
is valued for tax purposes. Section 2’s grant of legislative power to “define
the classes of property” would be meaningless were the intent of § 1 to treat
all types of real property the same for tax purposes. Cf. Davis v.
County of Greenville, 322 S.C. 73, 470 S.E.2d 94 (1996) (“A statute must
receive such construction as will make all of its parts harmonize with each
other and render them consistent with its general scope and object.”).

Section 1 does not prohibit the Legislature from
requiring different types of real property be valued the same. Instead, it
requires each category of property enumerated retain the same assessment ratio
as other property within its class. In other words, the South Carolina Constitution
requires that an assessment ratio be applied to eight distinct classes of property,
and that this assessment ratio must be uniform and equal to property within
each class. The methodology to determine the value of the property remains
a matter for the General Assembly.

Beaufort County’s reliance on Meredith,
Owings Mills, and Simkins, is misplaced. This Court in each case
interpreted a version of Article X since amended. Under the previous Article
X, the Legislature classified property, set the valuation method and set assessment
rates. See S.C. Const. art. X (1976) (“The General Assembly shall provide
by law for a uniform and equal rate of assessment and taxation, and shall prescribe
regulations to secure a just valuation for taxation of all property, real, personal
and possessory. . . .”). The amended Article X removed the Legislature’s ability
to set assessment rates in § 1 while maintaining its power to classify property
for valuation purposes and to establish valuation methods under § 2.

Meredith, Owings Mill, and Simkins
must be viewed in light of the former Article X. A closer reading of each opinion
reveals this Court did not use the term “assessment” to refer to the valuation
of property as Beaufort County insists. Instead, the term was used generically
to refer to the three-step process to determine the taxable value of the property.
Further, to read “assessment” to equal “value” is to ignore the explicit grant
of power to the Legislature in § 2 to “define the classes of property and values
for property tax purposes of the classes of property set forth in Section 1.”
S.C. Const. art. X, § 1 (emphasis added).

Section § 27-32-240 does
not violate S.C. Const. art. X. The Legislature is empowered to determine that
a “vacation time sharing ownership plan” is valued differently from a “vacation
time sharing lease plan” under the power granted by § 2. [2]

CONCLUSION

Accordingly, we AFFIRM the circuit court’s order.

TOAL, C.J., MOORE, WALLER and PLEICONES, JJ., concur.

[1]
Both Beaufort County and the State moved for summary judgment. Holtcamp
filed a motion supporting the State’s motion and opposing Beaufort County’s
motion. The circuit court granted the motion of State and Holtcamp. Beaufort
County’s motion for reconsideration was denied.

[2]
Additionally, Judge Thomas Kemmerlin’s order correctly notes the intent of
the Legislature in enacting § 27-32-240 was to statutorily prohibit the tax
assessor from stacking the purchase price paid for each week of time for each
time-share unit. Instead, the Legislature required an assessor to value only
the underlying land and building itself. In doing so, the Legislature mandated
that “time-share units are to be valued for tax purposes at what a single
owner would pay for the unit, not the aggregate price paid by all owners.”